Research On The Problem Of Base Erosion And Profit Shifting In Digital Economy

In June 2012,G20 finance ministers and central bank governors meeting agreed through international cooperation to deal with the problem of BEPS,and OECD commissioned research.In June 2013,OECD released the BEPS action plan,and in September at the G20 St Petersburg summit to be endorsed by the leaders of the country.Between October 2014 and May 2015,OECD held four special meetings and three communities for comments,in June 2014;the report of the digital economy in the face of tax challenges was introduced.So,the tax base erosion and profit transfer(BEPS)problem in digital economy has attracted worldwide attention.As the digital economy has broken through the traditional business model,the development of Internet and information technology,goods and transactions are not rigidly adhere to the physical form,the mobility of intangible assets increased.Multinational Internet companies use this feature to carry out malicious tax planning,BEPS risk surge,the source of government revenue in large scale weakened.According to the situation,this paper studies the BEPS problem in the background of digital economy.In this paper,first of all,the source of the BEPS problem,the formation of the reasons,the characteristics of the digital economy and its impact on the BEPS problem are described in detail,Points out that the Multi-National Corporation mainly through the tax jurisdiction,transfer pricing,capital weakening and anti-avoidance rules loopholes four means to circumvent the tax burden,However,due to the development of the digital economy,this problem has worsened,and constantly challenges the current international tax system framework,to promote the construction of the international tax system and the pace of economic development.Secondly,with the characteristics of the digital economy as the starting point,this paper expounds the problems of the tax base erosion and profit transfer in the digital economy.The difficulty of defining the concept of tax jurisdiction,the transfer pricing of intangible assets transfer pricing,the difficulty of data utilization and the qualitative issues of income.Finally,the author puts forward some related policy suggestions for this problem,starting from four aspects,First,improve the definition of the concept of tax jurisdiction,and put forward the "virtual permanent establishment",to make up for the blank of the management of network transactions.Second,for the transfer pricing,the value creation should be consistent with the tax,is strictly prohibited by reducing the value of the tax burden,vigorously promote the principle of market premium and cost saving,and seek more tax benefits for developing countries.Third,as a result of the development of digital economy as a prominent part of e-commerce,the establishment of a network of e-commerce tax collection and management system is also very necessary.Fourth,to strengthen international tax cooperation,the integration of the world economy and networking,close ties between the country,strengthen international cooperation is more conducive to combating global tax evasion Multi-National Corporation.